Top Accessibility Issues that Put You at Risk for EAA Non-Compliance

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Top Accessibility Issues that Put You at Risk for EAA Non-Compliance

Posted March 07, 2025

AudioEye

Posted March 07, 2025

Open laptop with a stylized web browser next to text reading 'EAA'. A shield with an accessibility symbol is in the top right-hand corner of the laptop.
Open laptop with a stylized web browser next to text reading 'EAA'. A shield with an accessibility symbol is in the top right-hand corner of the laptop.

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The European Accessibility Act (EAA) has strict accessibility requirements for digital content — and non-compliance can lead to expensive fines, penalties, and demand letters. Below, you’ll learn the top accessibility issues putting you at risk for non-compliance and how you can minimize your financial and business risk.

Does your website comply with the European Accessibility Act? And if not, what risks are you taking? 

The European Accessibility Act (EAA) is intended to standardize disability non-discrimination laws throughout the member states of the European Union (EU). As part of that mission, it requires conformance with the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, the international standards for digital accessibility.

The basic goal of the EAA is to improve the user experience for people with disabilities, and WCAG is an excellent basis. Unfortunately, most websites fail to meet those standards. A 2024 automated analysis from WebAIM found that 95.9% of the internet’s top 1 million home pages had detectable WCAG failures, with an average of 56.8 distinct accessibility errors per page.

And as of June 28, 2025, the EAA’s requirements will become enforceable for most types of private businesses. That means that organizations have a few months to make major improvements! 


Below, we’ll explain how the EAA applies to different types of organizations (including businesses based in the United States). We’ll also outline common conformance issues that are likely to result in fines or lawsuits — and explain how you can build a long-term strategy for EAA compliance.

Understanding EAA Website Compliance and its Risks

First, we need to address a common misunderstanding: The EAA isn’t a single law. It’s a set of harmonized technical standards, which are intended to ensure that all of the EU members have the same requirements for public-facing websites.

The EAA sets those requirements (namely, WCAG 2.1 Level AA) and mandates that each member state transpose it into their national laws. That means that there isn’t a single set of consequences for noncompliance — member states are responsible for setting fines and other mechanisms of enforcement.

For businesses, that’s an important point for understanding legal risks: An organization that operates in multiple countries might face separate fines or digital accessibility lawsuits in each country for proven violations. 

A few quick examples: 

To learn more about non-compliance fines, read: The Cost of EAA Violations and Their Legal Consequences.

While financial penalties vary, more severe violations generally lead to bigger consequences. For example, public-facing government agency websites are more likely to face serious penalties than a small business — but virtually every organization could face lawsuits, and repeat offenders can expect to pay for non-compliance.

That includes businesses based in the United States. If your business serves customers in the EU, you’re required to meet WCAG. The good news: WCAG also serves as the de facto compliance requirement for the Americans with Disabilities Act, so improving digital accessibility will help limit legal exposure in all markets.

A stylized web browser with a number of accessibility issues highlighted by red exclamation points, next to icons of a wrench and some gears.

Top Accessibility Issues that Lead to EAA Non-Compliance

Technically, any WCAG failure could violate the EAA's accessibility standards. However, from a legal perspective, the most significant issues are barriers that are likely to affect a large number of users. 

However, there are some common WCAG issues that are particular points of concern for EAA compliance.

1. Missing Alternative Text (Alt Text)

Alternative text (or alt text) describes images and other non-text content, which makes visuals accessible for users who are blind or have low vision. Screen readers can announce the text out loud or convert it to braille. If the image fails to load for any reason, alt text can also be helpful for visual users.


Adding alternative text takes a few seconds, and doing so improves search engine optimization (SEO). It’s one of the easiest accessibility features to implement — and one of the most frequently ignored.

2. Poor Color Contrast (or Low-Contrast Text)

When text doesn’t have enough contrast with its background, it’s more difficult to read. For some people with color vision deficiencies (sometimes referred to as color blindness) or visual impairments, it may be impossible to read — and important information may be completely inaccessible.

WCAG 2.1 specifies that normal text should have a contrast ratio of at least 4.5:1 with its background color, and large text should have a ratio of 3:1. That’s applicable for all types of digital content, but if designers aren’t aware of the requirement, they’ll often make mistakes.


Tools like AudioEye’s Color Contrast Checker can analyze color combinations and determine if they meet WCAG standards. Addressing poor color contrast improves experiences for all users, and given that it’s frequently listed in ADA accessibility demand letters, it’s a likely target for EAA compliance enforcement.

3. Keyboard Navigation Issues

Keyboard accessibility is crucial for people who use screen readers and other assistive technologies. Many people with disabilities don’t use a mouse at all when browsing the internet — so if your website doesn’t work with a keyboard alone, it’s not accessible for those users.

Some quick examples of common keyboard navigation issues:

  • A missing or illogical tab order (or focus order) might prevent people from navigating through interactive elements in a way that makes sense.
  • “Keyboard traps" may prevent users from escaping from specific elements (such as embedded media). 
  • Some dropdown menus are designed to respond only to mouse hover events.
  • Many websites are missing “skip navigation" links, which allow users to bypass lengthy navigation menus that appear on every page.

All of these issues are fairly easy to resolve, but they’re serious frustrations for keyboard users.

4. Missing Captions and Transcripts for Video and Audio Content

Captions are a valuable feature, period. One study performed by language learning platform Preply, about 50% of Americans said that they use subtitles “most of the time" when watching content. 

For individuals with sensory disabilities, captions and transcripts may be essential. Both are necessary under WCAG: While captions are primarily intended for users with hearing disabilities, transcripts are intended for people with vision disabilities.

5. Inaccessible eCommerce Experiences

eCommerce websites are frequent targets for web accessibility lawsuits for several reasons. First, they’re often relatively large: Many sites have thousands of products, all of which must be optimized to meet WCAG. 

Additionally, eCommerce sites tend to be complex. Accessibility barriers are often introduced during the checkout process:

  • CAPTCHAs and other security features may lock out people who have hearing or vision disabilities. 
  • Payment platforms may be incompatible with assistive technologies.
  • Forms may be missing labels and accessible names, which may make them impossible to complete with screen readers.
  • Product images may be missing accurate alt text. 


In a 2022 analysis, we found that 83% of e-commerce sites had severe accessibility issues, with an average of 203 issues per page. 20% of those issues were severe enough to impact a user’s ability to interact with the content — yet only 1% of those sites used some form of digital accessibility solution.

6. Empty, Broken, and Redundant Hyperlinks

Hyperlinks are fundamental to web navigation, so when they don’t work, they’re a big issue for compliance. Most link accessibility issues fall into three categories: 

  • Empty Links: Links that lack any text or clear purpose, which can be confusing for screen reader users.
  • Broken Links: Links that lead to non-existent pages.
  • Redundant Links: Multiple links that point to the same destination.

Most hyperlink issues can be resolved with automation, though some require a human touch.

Stylized web browser with the accessibility symbol next to it. A raised gavel is on the right-hand side of the browser.

How to Protect Your Organization from EAA Non-Compliance

While each EU member state sets its own regulations for accessibility compliance, the EAA’s harmonized standards are an asset for businesses. You don’t need to read through dozens of laws to avoid daily fines, costly demand letters, and other consequences of non-compliance — you simply need to conform with WCAG 2.1 Level AA. 

Here are some simple steps you can take today to start planning for compliance:

  1. Check your website against WCAG checkpoints. Tools like AudioEye’s Free Website Accessibility Checker scan for common WCAG issues, giving you an overview of your current level of EAA compliance.
  2. Have a plan for manual reviews. Accessibility audits should include manual testing performed by accessibility experts and assistive technology users. 
  3. Build WCAG into your content creation process and training. Many accessibility issues are easy to resolve when you’re building documents or websites; they’re more difficult (and expensive) to fix after the fact. Following WCAG best practices and holding regular accessibility training can help you take a more proactive approach to EAA compliance.
  4. Publish an accessibility statement. An accessibility statement tells your audience about the steps you’re taking to create inclusive online experiences.
  5. Treat accessibility as a priority, not a project. You’ll need a long-term strategy for testing your content and resolving errors.

This last point is especially important for compliance! Every change you make to your website could potentially introduce new accessibility barriers — for sustainable compliance, you’ll need regular audits and user testing.

Start Your Path to EAA Compliance with Expert Support

EAA compliance is achievable, regardless of your organization’s budget. As we’ve discussed, many accessibility improvements cost little to nothing to implement. And while some improvements require an investment, it’s an investment that pays off: Accessible design leads to improved SEO, lower long-term development costs, and improved engagement with your target audience.

The June 28, 2025 deadline is rapidly approaching, so if your organization hasn’t prioritized online accessibility, it’s time to get started. And with AudioEye, your path to EAA compliance is fast, easy, and cost-effective.

With our three-pronged approach to accessibility, you achieve industry-leading compliance with accessibility standards, including the EAA. Our comprehensive approach to accessibility testing that combines both AI-driven automation technology and audits with experts from the disability community saves you time and up to 90% in costs compared to traditional methods. Plus, with AudioEye Assurance, you’ll enjoy a level of protection that’s 400% better than consulting or automation-only approaches.


Don’t wait for legal action to meet EAA compliance requirements. Get started with a free website accessibility scan. Or schedule a demo to see how AudioEye provides you with a genuine guarantee of accessibility compliance.

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